The Small Business Association’s infamous climate-change report predicted that implementing AB 32 would create an economic doomsday that would permanently erase 1.1 million jobs, and cause a 26% decline in discretionary spending by California households among other ridiculous findings. The report is a prime example of why Governor Brown calls his climate change opponents “troglodytes”, and it was universally and very publically blasted by academic experts, and even the LAO.

In this pro-tunnels Sac Bee op-ed, Ms. Toccoli, the long-serving President of the California Small Business Association, once again shows an inability to interpret an economic report, a lack of understanding of environmental projects/policies, and a taste for bogus, doomsday economic scenarios.

Here is a look at the 4 “facts” she uses to support the tunnels.

First, she dismisses the importance of the 50-year regulatory assurance from an ESA section 10 permit that is no longer in the plan. Never mind the permit, she says without the tunnels we face

“a guaranteed future of diminishing water supplies if we fail to act. According to economist David Sunding, without a new conveyance system, if wildlife agencies impose continued or even greater flow restrictions to protect fish, we could lose more than 1 million acre-feet of water supply a year.”

Wrong. Dr. Sunding’s scenario was intended to capture the benefit to water exporters of the regulatory assurance from the BDCP’s proposed 50-year permit that was the hoped for result of the combined conveyance and habitat restoration plan. It does not stem from building the tunnels as she claims. It’s irrelevant now, because the revised Water Fix plan does not include this element. The water exporters have no regulatory protection from an increase to flows that may be needed to protect fish, even if they build the tunnels. It is well known that they are extremely concerned about this important change that Ms. Toccoli dismisses.

Second, and most importantly, she wildly overstates the earthquake risks and consequences, misrepresenting the protection offered by the tunnels a 100 times with some numbers taken out of context from an old report. She concludes,

“The total cost of disruption to our water system would cost the economy $30 billion to $40 billion over five years – more than twice the total construction costs of the pipelines.”

Wrong on multiple levels. First, I will point out that the report she authoritatively cites in her first argument, estimated the cumulative avoided costs of the earthquake scenario at $400 million over 50 years, 1% of the value Ms. Toccoli uses. And unlike regulatory assurance, the amount of earthquake protection is something that is unchanged between the 2013 BDCP proposal and the 2015 Water Fix. That means Sunding’s report is a current source for valuing earthquake protection, but outdated on water yield and regulatory protection.

Here is the source she is using to support her claim of $30-40 billion in costs.

She assumes a ridiculous 6 year disruption. Even DWR says it would be “weeks or months” which is the far left corner of this graph where the costs in billions are low single-digits and hard to distinguish from zero in some cases.

She assumes the tunnels protect from all of these costs. In fact, DWR’s documents show exports would still decline by about 50% with the tunnels in place, so the tunnels only protect against about half of these costs.

She uses the top-line economic impacts, when the lower bottom set of lines, economic costs, are the appropriate measure to use for comparing to the cost of the tunnels.

Her 68% probability of a catastrophic 20+ island flood over the next 25 years is inflated too, although it is often cited as the probability of a large quake in the Bay Area that could damage delta levees.

Rather than plucking numbers out of context from obscure reports that she does not appear to understand, I recommend using a common sense comparison to other water surface-water shortages. In the unlikely event of a Delta-destroying earthquake flood, the tunnels would protect 50% of Delta exports for a period of weeks or months according to DWR. That’s a shortage of about 1 maf of surface water supplies, a significant shortage, but one that the state already has plenty of experience managing. In fact, it’s only about 10% of the loss of surface water supplies in the current drought, and the economy still grows robustly. The disaster talk to water supplies sounds much scarier than the reality. We should be more focused on water shortages from an extended drought (a scenario where the tunnels do little to help), and less afraid of water shortages from a Delta earthquake.

And like most tunnel proponents, Ms. Toccoli callously ignores the death and destruction in the Delta itself from the disaster scenario she is hyping for water exporters. Seismic levee upgrades would actually offer more protection for water exports than the tunnels, and would save lives and other vital transportation, energy and water infrastructure that benefit her small business supporters. Why keep pushing expensive and divisive tunnels instead of a lower-cost, win-win alternative?

Third, she makes a claim about wet year water exports that is mostly a repackaged version of the invalid first argument. The wet year yields described in the EIR/EIS are not as large as she claims. It is just a repeat of the argument that the tunnels benefit water exporters because they are hoped to stave off more environmentally-protective operating rules in the future. As I have pointed out previously, this line of argument directly contradicts the EIR/EIS.

Fourth, she makes an inaccurate comparison to the costs of alternatives.

A comparison of various alternatives shows the relative affordability of California WaterFix. The cost of water will be approximately $1,000 per acre-foot for Southern California and less than $500 per acre-foot for Central Valley farms. A recent recycled water project in San Francisco came in at more than $8,000 per acre-foot, while the Poseidon desalination plant in San Diego comes to more than $2,200 per acre-foot.

Wrong again. A consistent and correct comparison focuses on the incremental or marginal costs of alternative projects. Ms. Toccoli’s figure averages the cost of the tunnels across all 4.9 maf of expected exports after the tunnels are built, including spreading the costs over the roughly 4.7 maf that water exporters would receive anyway.

The San Diego desalination plant is 100% new water supply to the system, all 56,000 af of yield is an incremental new supply. A valid comparison to the tunnels, only looks at the new incremental water yield that results, which is a little over 250,000 acre feet according to the EIR/EIS. Veteran water economist Rodney Smith published a handy table that shows the cost of water from the tunnels under various assumptions of incremental water yield. At the yields in the latest EIR, the tunnels water supplies are over $3,000 per acre foot. Not only are the tunnels more expensive than desalination, their water supply is less reliable, lower quality, and hundreds of miles away from where it would be used. Of course, the choice isn’t really tunnels vs desal, but tunnels versus myriad alternatives including fixing leaking pipes, recycling, stormwater capture, groundwater clean-up, and conservation that the state has not come close to fully developing. Desalination is the most expensive alternative, and used for comparison only to highlight the tunnels’ extreme cost.

The article wraps up with the $5 per month ($60 per year) cost which it describes as “a pittance.” That will only pay for Metropolitan Water District’s 25% share, and is hardly a pittance to many households. The tunnels will cost some irrigation districts hundreds of millions of dollars each year, and there are individual farming operations that could be on the hook for a million or more each year. The word pittance best describes the tunnels’ contribution to the State’s water supply, and its cost is best described as by far the most expensive and risky water supply investment in the State’s history.

Ms. Toccoli is a savvy political player with a lengthy history of political advocacy which includes passing out coveted business endorsements to Democrats. I don’t know about her positions on other issues, and perhaps she is a positive factor in other discussions. But her inaccurate forays into economic analysis of environmental issues have distorted serious policy debates, and are ultimately unhelpful to the small business interests her organization represents.

About the Author

Ethan Jacob

Author & Editor

I am Ethan Jacob Executive Director of the Center for Business and Policy Research at the University of the Pacific, where I have a joint faculty appointment in the Eberhardt School of Business and the Public Policy Program in the McGeorge School of Law..